Conflicts of Interest Policy

In order to act with complete impartiality and retain the trust of its clients, STAM France Investment Managers has established and maintains a policy for the prevention and management of conflicts of interest, which is set out in the Code of Ethics issued to all employees.

STAM France Investment Managers has mapped out the situations that could potentially give rise to conflicts of interest in the course of its business activities and, on this basis, has established a system for preventing and detecting conflicts of interest.

The main principles of the system are as follows:

• Implementation of a procedure for selecting service providers;
• Remuneration policy;
• Detection of conflicts of interest;
• Maintenance of a repository and a register of conflicts of interest encountered;
• information des clients lorsque des conflits d’intérêts n’ont pu être résolus.